Purchasing

KCD.009.01 Issue 1707-18-2018

Kurt Manufacturing CompanyQuality Control Procurement Clauses

The following clauses specify the Kurt Manufacturing Company quality requirements. Additional or Supplemental quality requirements may be specified in the body of the purchase order. Quality records are to be maintained on site at seller’s facility, for a minimum of 7 years or specified on the purchase order. The clauses do not supersede the terms and conditions of the purchase order.

General Requirements for all Purchase Orders

The requirements stated below shall apply to all suppliers of Materials and processing services furnished to Kurt Manufacturing.

All material supplied or processed shall conform to the latest revision level of the applicable specification. The supplier is responsible for flow down to sub-tier suppliers, all applicable requirements in the purchasing documents, including key characteristics where required.

For any departure from the purchase order, specification, or drawing, the supplier will submit to Kurt Manufacturing Company, through Purchasing, a Request for Deviation Waiver. The seller must notify Kurt Manufacturing Company of any changes to the product. In addition upon first article approval. Kurt Manufacturing. requires all suppliers and their sub-tier suppliers to give no less than 180 days written notice of any change in the manufacturing processes, including but not limited to, relocation of production facilities, obsolescence of components and changes in processing equipment or design, Please submit written notifications to the buyer listed on the purchase order changes.

All Non-Conforming product must be immediately reported to Kurt Manufacturing purchasing, shipping of Non-Conforming product without written approval is not allowed. Notice of Escape of non-conforming product must be reported immediately.

Suppliers shall adhere to and flow down to the supply chain The EICC code of conducted. You may obtain additional information from http://www.eiccoalition.org/

All materials provided to Kurt Manufacturing must conform to section 1502 of the Dodd- Frank Act (Conflict Minerals)

Aviation & Defense Suppliers

For aviation and / or defense work a legible and reproducible certificate of conformance must accompany each shipment. A legible and reproducible test report shall be provided with each Special Process, i.e. welding, heat treating shipment. Seller shall certify and maintain objective evidence (traceability) that all items purchased or manufactured by the seller for this purchase order comply with the applicable standards or specifications. All items requisitioned by this purchase order may be subject to source surveillance by a Kurt Manufacturing Company quality representative and / or Kurt Manufacturing Company Customer Representative. This may include surveillance of the seller’s system, procedures, facilities and product. For any departure from the purchase order, specification, or drawing, the supplier will submit to Kurt Manufacturing Company, through Purchasing, a Request for Deviation Waiver. The seller must notify Kurt Manufacturing Company of any changes to the product and / or process for all lots run after first article acceptance. Records to be maintained for notification and Kurt Manufacturing Company approval.

Kurt will only purchase products to be delivered or incorporated as goods to buyer or customer directly from the Original Component Manufacturer (OCM) \ Original Equipment Manufacturer (OEM), OCM \ OEM authorized distributor chain, aftermarket manufacturer, or authorized reseller. These products shall have verification that goods are traceable to OCM \ OEM; OCM \ OEM authorized distributor chain, aftermarket manufacturer, or authorized reseller that identifies the name and location of all the supply chain intermediaries from the part manufacturer to the direct source of the product. If Goods can only be acquired from independent distributors or brokers in cases of diminishing material supply (DMS) or obsolescence, written notice shall be provided to the customers prior to procurement of these goods

Packaging Requirements

Packaging shall conform to all requirements in acordance with all or any statuatory or regulatory requirements and requirements specified on drawings, specifications, purchase order and materials shall be packaged after outplant services the same as or better than as received from Kurt Manufacturing. In addtion materials shall be wrapped, bagged and enclosed in cartons, boxes, or other containers which will provide protection from contamination and physical damages.

THE FOLLOWING ARE SPECIFIC QUALITY CONTROL PROCUREMENT CLAUSE REQUIREMENTS AND ARE APPLICABLE WHEN NOTED ON THE PURCHASE ORDER

1. Quality Program Requirements

The seller shall provide and maintain a system that complies with “Quality Program Requirements.” Compliance with the provision of this clause in no way relieves the seller of the final responsibility to furnish acceptable supplies or services.

The seller’s system shall be subject to audit by Kurt Manufacturing representatives.

The seller shall prepare and maintain a system that complies with ISO, “Supplier Quality Assurance Program Requirements.” Compliance with the provision of this clause in no way relieves the seller of the final responsibility to furnish acceptable supplies or services. The seller’s system shall be subject to audit by Kurt Manufacturing representatives.

2. Inspection System Requirements

The seller shall prepare and maintain a system that complies with “Inspection System Requirements.” Compliance with the provision of this clause in no way relieves the seller of the final responsibility to furnish acceptable supplies or services. The seller’s system shall be subject to audit by Kurt Manufacturing representatives.

3. Inspection and Test Instructions

The seller shall prepare and maintain written plans and instructions for inspections and tests performed in compliance to this purchase order. These documents must include item part number revision, equipment used, and operational sequence, accept / reject criteria, sampling plan, special process procedures and approvals, and evidence of control. The Plans / instructions must be submitted to Kurt Manufacturing Company for Quality Assurance approval at least two (2) weeks prior to fabrication.

4. Standard Inspection System Requirements

To assure purchase order requirements compliance, the seller shall provide and maintain an inspection system acceptable to Kurt Manufacturing Company. The system shall provide sufficient inspection, records, control and traceability to ensure compliance to purchase order requirements. The seller’s system shall be subject to audit by Kurt Manufacturing representatives.

5. Tool Proofing

Acceptance of production tooling against this purchase order shall be contingent upon inspection and acceptance by Kurt Manufacturing Company of the applicable characteristics. Dimensional samples (quality designated by purchase order produced by this tooling) must conform to tolerance limits of the drawing and specification specified by this purchase order. When duplicated tools are made to the same tool number, each must be proved separately. Any rework of a tool after proofing (beyond its normal maintenance) shall require subsequent proofing and approval by Kurt Manufacturing Company. Seller shall maintain process records for molded parts to include: mold release agents used temperatures, pressures and time cycle data for preheat, molding and cure, as applicable.

Tool proofing acceptance shall be under surveillance of the cognizant Kurt Manufacturing Company quality representative at the seller’s facility. Seller shall furnish a legible and reproducible copy to tool proofing approval with the initial shipment. Approval shall list the tool number and inspection variable data, signed or stamped and dated by the Kurt Manufacturing Company quality representative.

Dimensional Samples and the Seller’s variable data shall be shipped to the Buyer to support acceptance inspection the samples and data must be identified with the tool number or individual cavity number as applicable.

6. First Article Inspection

Compliance to purchase order requirements shall be determined by inspection, utilizing applicable drawings and specification, to a specific quantity denoted below unless otherwise specified by the purchase order. First article item(s), when submitted to Kurt Manufacturing Company, shall be accompanied by the seller’s first article report. First article item(s) must be inspected and indemnified by tool number, serial number and when applicable, cavity number.

Note: First article is only required on initial shipment. Subsequent first articles shall be performed if 12 months have passed since the last production run, part has a revision change, or a change in the manufacturing process has changed since last production run.

First Article Inspection Code:

One first article from each cavity

One first article part required

Two first article parts required

Three first article parts required

Other (refer to purchase order

First Article in accordance with SAE AS 9102

First Article shall be submitted through Net-Inspect online

7. Test Specimens (Castings/Forgings)

The seller shall furnish with each shipment of castings or forgings, test specimens which conform to ASTM E8. Specimens shall be identified with the purchase order number, melt number heat treat number, lot number and alloy identification.

8. Certificate of Conformance

A legible and reproducible certificate of conformance must accompany each shipment. This certificate must reference the purchase order number, part number, revision (plus any applicable waivers, ECO’s or deviations), quantity shipped, date(s) shipped, shipper number, applicable specifications (with revision) of materials, and special processes. When items are serialized, serial numbers must be included. Material furnished by Kurt Manufacturing Company must be referenced, including traceability to the lot number indemnification. The certification must include the signature and the title of seller’s Quality Assurance representative. Kurt Manufacturing Company or Suppliers equivalent shall be used.

9. Test Reports

A legible and reproducible test report shall be provided with each shipment. Each test report shall evidence compliance with the applicable drawing and / or specification requirements and shall include the revision of the drawing and / or specification. The reports shall bear the signature and title of the responsible agent of the seller. When serialization of items has been imposed by the purchase order, such serialization shall be part of the test report.

Nondestructive tests shall be performed by qualified personnel. Seller’s findings shall be reported on an appropriate from, including the name of the reader and the signature of the responsible agent. The firm and report shall accompany the shipment of the material. An adequate method of identifying and cross-referencing each file exposure, report and item must be provided.

10. Test Certification

Each Shipment must be accompanied by a certification stating that reports, which assure conformance to drawing and / or specification requirements, are on file and available for examination. When Kurt Source Inspection is imposed, test reports shall be presented with the product for review. The certification must be identifiable with the product submitted and must contain the signature and title of the seller’s Quality Assurance representative.

11. Special Process Approval

Special process such as, but not limited to: welding, heat-treating, liquid oxygen cleaning, electro polishing, anodizing, chemical films and nondestructive testing (e.g. helium leak testing, penetrant, etc.) and any subcontracting thereof, require approval or certification of process equipment, procedure and personnel, as indicated by the applicable drawing, specification or standards. The approval must be established with Kurt Manufacturing Company prior to fabrication or processing under the purchase order.

12. Standard Hardware

Seller shall certify and maintain objective evidence (traceability) that all items purchased or manufactured by the seller for this purchase order comply with the applicable standards or specifications (e.g. MIL-STD, MS. NAS, etc).

13. Source Inspection, Product Testing

All items requisitioned by this purchase order are subject to inspection at the seller’s facility by a Kurt Manufacturing Company quality representative prior to shipment. Detailed parts or assemblies are subject to inspection by the quality representative prior to shipment. The seller shall make available their inspection records to the Kurt Manufacturing Company quality representative at the time of presentation of produced item. The seller shall provide no less than seventy-two (72) hours advanced notice to the Kurt Manufacturing Company quality representative to permit proper scheduling of source inspection. Evidence of source inspection must be shown on the shipping documents. Seller shall provide suitable facilities and equipment to support this effort.

14. Access Clause, Kurt Manufacturing Company

All items requisitioned by this purchase order may be subject to source surveillance by a Kurt Manufacturing Company quality representative and / or Kurt Manufacturing Company Customer Representative. This may include surveillance of the seller’s system, procedures, facilities and product. The seller shall, at no additional cost, supply inspection records and when requested, perform or repeat selected inspection and / or tests which are required by drawing, specification or inspection instructions.

15. Source Inspection, Government

Government Inspection is required prior to shipment from your plant. Upon receipt of this order, promptly notify the Government representative who normally services your plant so that appropriate planning for Government Inspection can be accomplished. In the event that a Government representative cannot be located, inform Kurt Manufacturing Company Purchasing. Evidence of Government concurrence must be shown on all discrepancy reports. All discrepancy reports must include description of defect, cause, corrective action, and affectivity statement.

16. Access Clause, Government

During performance on this purchase order, the seller’s quality control, inspection system and manufacturing process are subject to review, verification and analysis from an authorized Government representative. Government inspection or release of product is not required prior to shipment. The seller shall provide a copy of this purchase order to the Government upon request.

17. Shelf-Life Material

Seller shall identify each item, package or container of shelf life material with the cure or manufacturing date, expiration date, special storage and handling conditions in addition to the normal identification requirements of name, part or code number, specifications number, type size, quantity, etc. This identification, including special handling conditions, shall be recorded on the certification and shipping documents.

Seller shall furnish a legible copy of certification of items incorporating a shelf-life material that does not require age control after installation (e.g. adhesives, resins, plastics based paints, etc.). Certification shall state that the shelf-life material were properly controlled prior to use and within the shelf-life period when incorporated. The certification shall be identified with the purchase order number and the item(s) produced, and must also contain the signature and title of the responsible seller agent.

Shelf-life materials must have no less then six months shelf life prior to expiration date.

Shelf-life materials must have at least twelve months remaining shelf life prior to expiration date.

18. Traceability

Material used must be identifiable by lot number, material type, specification and revision letter(s), heat number, etc., and traceable to records of inspection acceptance. Items fabricated by the seller shall be identified with the lot of material used. When two (2) or more parts are joined in an assembly, the seller shall prepare an assembly parts list identifying each item in the assembly. Traceability records shall be available for review by a Kurt Manufacturing Company quality representative.

All parts and / or material, and applicable documents must be identified by a manufacturing lot number or batch number by the seller. (A lot or batch number is defined as parts and / or material produced by one manufacturer in one unchanged process, in accordance with the same drawing and / or specification revision.

Seller shall serialize parts and /or material at the seller’s facility when serialization is designated by the purchase order. No two (2) items of the same part number (on this or any other Kurt Manufacturing Company purchase order) are to be assigned the same serial number.

Origin of raw material must be domestic. (Producing mill must be within the United States of America).

Producing mill certification required.

19. Qualified Products List (QPL: Certifications)

(Qualified product from manufacture or distribution on QPL): Manufacturer or distributor shall furnish with each shipment the name and the commercial designation of the product, on the items, affixed by label or nameplate or preprinted on the wrapping, on the accompanying certification.

20. Request for Deviation / Waiver Report (DD1694)

For any departure from the purchase order, specification, or drawing, the supplier will submit to Kurt Manufacturing Company, through Purchasing, a Request for Deviation Waiver (DD1694). All requests must be approved by prime contractor and government concurrence.

21. Inspection Equipment List (IEL)

The inspection equipment required to perform the tests and examination for this purchase order must be itemized on the IEL.

Seller may use Standard Measuring Equipment (SME) that is traceable to the National Institute of Standards and Technology; however, any special inspection equipment must have designs submitted to Kurt Manufacturing Company for Approval. Seller designs shall be supported by detail drawings, which depict all information necessary to completely fabricate, calibrate and operate

The equipment. This requires that the necessary views, dimensions, material, finishes, notes, and operations and calibrations instructions be properly depicted in accordance with approved practices to the extent that further calculation or clarification will not be required. Designs may be developed on a format normally employed in the seller’s equipment design procedure, provided such format reflects the detail and information specified above and its conformance to DOD-D-1000, level 2, MIL-HNDBK 204and MIL-G-10944. IEL’s and equipment design may be subject to government review and approval.

22. Statistical Process Control

The Subcontractor is required to validate the quality of the product using Statistical Process Control (SPC) techniques as defined in American National Standards Institute (ANSI). A plan for the implementation of SPC shall be submitted by the subcontractor for review and approval by Kurt Manufacturing Company prior to production. Where a first article is contractually required, availability of the SPC plan will be required prior to first article inspection by Kurt Manufacturing Company. Notification of acceptance or rejection shall be furnished to the subcontractor through the buyer / subcontract administrator. All SPC inspection records, failure reports, capability studies, corrective actions reports and control charts shall be maintained and available for Kurt Manufacturing Company and Government review for a period of three (3) years. Scrap and rework records must also be readily available for Kurt Manufacturing Company and Government review for a period of three (3) years. Copies of SPC inspection records shall be presented with each shipment for review by Kurt Manufacturing Company Quality Engineering.

23. Certified Suppliers

The subcontractor is approved as a Kurt Manufacturing Company Certified Supplier and, as such, is authorized to ship the items listed on this purchase order using the Kurt Manufacturing Company acceptance stamp provided. Certification of Conformance and packing lists and / or shippers shall be stamped by the subcontractor’s quality representative for each shipment using the acceptance stamp provided.

24. Supplier Data

A legible, reproducible copy of the seller’s record of the nature of the observation regarding product(s) acceptance must accompany each shipment. The records must be traceable to the lot of components, subassemblies or assemblies shipped.

25. Kurt Manufacturing Company Inspection

All material / items on this purchase order are subject to receiving inspection.

26. Government Receiving Inspection (at Kurt Manufacturing Company)

All material / items on this purchase order are subject to Government receiving inspection.

27. Lot Number Control

All material / items on this purchase order must have a lot number.

28. Customer Verification of Subcontractors Product

The customer of Kurt Manufacturing Company or the customer’s representative reserves the right to verify our suppliers system, procedures, facilities and products. This verification will not be used by the supplier as evidence of effective control of quality.

This verification shall not absolve the supplier of the responsibility to provide acceptable product, nor shall it preclude subsequent rejection by Kurt Manufacturing Company or our customer.

29. Delivery Performance

100% on-time delivery is a requirement of this purchase order. If 100% on-time shipments are not maintained, the seller shall implement corrective action to improve delivery performance including communication of deliver problem information to Kurt Manufacturing Company.

30. Production Part Approval Process

The seller shall fully comply with the requirements set forth in the Production Part Approval Process (PPAP) manual published and available from AIAG. Production part approval is granted for each part number. Revision level, manufacturing location, production process environment and supplier. Changes to any of these require notification of Kurt Manufacturing Company and possible resubmission.

31. Restricted Substance

The seller will have a process to assure that government and safety constraints on restricted, toxic and hazardous substances are complied with relative to purchased products and the manufacturing process. Evidence of compliance will be submitted to Kurt Manufacturing Company upon request.

The seller will have a process to assure compliance to REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) requirements as established by the European Union.

32. Quality Management System Requirements to ANSI / ISO / ASQ 9001

The seller shall have a quality management system that complies with the requirements of the ANSI / ISO / ASQ 9001. Compliance to the provision of this clause in no way relives the seller of the responsibility to furnish acceptable supplies or services. The sellers system shall be subject to audit Kurt Manufacturing Company.

The seller shall have a quality management system that is registered to the requirements of ANSI / ISO / ASQ 9001 Compliance to the provision of this clause in no way relives the seller of the responsibility to furnish acceptable supplies or services. The sellers system shall be subject to audit Kurt Manufacturing Company.

33. Quality System Requirements to ISO / TS 16949

The seller shall have a quality management system that complies with the requirements of ISO / TS 16949. Compliance with the provision of this clause in no way relives the seller of the responsibility to furnish acceptable supplies or services. The seller’s system shall be subject to audit Kurt Manufacturing Company.

The seller shall have a quality management system that is registered to the requirements of ISO / TS 16949. Compliance with the provision of this clause in no way relives the seller of the responsibility to furnish acceptable supplies or services. The sellers system shall be subject to audit Kurt Manufacturing Company.

35. Notification of Product or Process Change by the Seller

The seller must notify Kurt Manufacturing Company of any changes to the product and / or process for all lots run after first article acceptance. Records to be maintained for notification and Kurt Manufacturing Company approval

36. Foreign Object Detection/Damage/Debris (FOD)

Supplier has sole responsibility to visually inspect for FOD and ensure that prior to closing inaccessible, and obscured areas and compartments during assembly, all debris is removed. Supplier shall inspect for foreign objects, such as materials, personal items, contaminates, or anything not part of the part/assembly, and ensure area is free of FOD barriers which may remain embedded. Seller shall ensure that tooling, fixtures, and test handling equipment are maintained in a state of cleanliness, by delivering items to buyer, supplier/seller shall be deemed to have certified to buyer that such items are free from any foreign materials that could result in FOD.

Added items c and d to section 17 Shelf Life. Also moved Revision Issue date and page number to Header

Reviewed by Jeff McIntosh, Brad Carlstrom, PJ Vollmer on 6-19-2014

09

Add Clause 36. Foreign Object Detection/Damage/Debris (FOD)

Reviewed by PJ Vollmer on 9-30-2014

10

Add f. to Clause 6 FAI SAE AS 9102

Reviewed by PJ Vollmer on 1-12-2015

11

Added to the general Requirements: For aviation and / or defense work a legible and reproducible certificate of conformance …….. Records to be maintained for notification and Kurt Manufacturing Company approval. Also Packaging

Reviewed by PJ Vollmer on 4-17-2015

12

Added statement to GENRAL REQUIREMENTS ALL PURCHASE ORDERS to cover supplier non-conforming material. And Supplier’s shall adhere to and follow down to the supply chain The EICC code of conducted. Also removed reference to MIL- Q 9858A in clause 1 and MIL-I- 45208A in clause 2. And changed reference to ASQ Q9001-2008 to ASQ 9001in clause 32